BACK v. VANORE
5:25-cv-01413
E.D. Pa.Jul 1, 2025Background
- Jared H. Back, an inmate at SCI Waymart, filed a pro se § 1983 civil rights complaint against Pennsylvania State Trooper Francis J. Vanore, III, alleging violations stemming from his 2023 DUI arrest.
- Back was arrested after a traffic stop, field sobriety tests, and a blood draw to which he claims he did not consent voluntarily.
- At his criminal trial, Back argued that he was coerced into consenting to the blood draw, but was convicted of multiple offenses, including DUI, blood alcohol violation, and drug possession.
- Back contends that Vanore’s conduct led to a wrongful conviction and resulting imprisonment, causing him emotional distress and financial harm; he seeks monetary damages.
- Back’s state criminal conviction remains valid and unchallenged on direct appeal; his PCRA petition was denied and he is still incarcerated.
- The matter before the court is the motion to proceed in forma pauperis and statutory screening of the complaint under 28 U.S.C. § 1915(e)(2)(B).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the § 1983 claim for unlawful blood draw and resulting conviction state a claim? | Back argues Vanore's actions coerced his consent to a blood draw, making the search unreasonable under the Fourth Amendment, and his conviction unlawful. | Vanore (implicitly) relies on Heck v. Humphrey and sovereign immunity, asserting that the claim is barred because the conviction is still valid and official capacity claims are not permitted. | The court holds that the claim is barred by Heck; success would undermine the outstanding conviction, so the case is dismissed without prejudice. |
Key Cases Cited
- Heck v. Humphrey, 512 U.S. 477 (1994) (bars § 1983 damages claims challenging a conviction unless the conviction has been invalidated)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for plausibility)
- West v. Atkins, 487 U.S. 42 (1988) (§ 1983 requirements for acts under color of state law)
- Brower v. Cnty. of Inyo, 489 U.S. 593 (1989) (defining searches and seizures under the Fourth Amendment)
- Schmerber v. California, 384 U.S. 757 (1966) (blood tests are searches under the Fourth Amendment)
- Will v. Mich. Dep't of State Police, 491 U.S. 58 (1989) (official capacity claims as claims against the state barred by the Eleventh Amendment)
- Hafer v. Melo, 502 U.S. 21 (1991) (distinguishing personal and official capacity suits)